[Key Air LLC Oxford, CT] [12/19/2013]

US Department of Transportation 

Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE.

 WASHINGTON, D.C. 20590 USA

Reference: Docket No FAA-2006-26135- Flight data recorders: filtered data Regulation, Final Rule

Please contact [Gary Nylund] Tél: 631-605-4243 Fax: 

mailto [3 Juliano Dr Suite 201 Oxford, CT 06478]

SUBJECT: [Falcon 2000LX S/N 155 & N606TJ] - Petition for Exemption

Applicable to: Flight data recorders: filtered data Regulation
Dear Sir or Madam:

In accordance with the provisions of Title 14, Code of Federal Regulations (14 CFR) §11.61, [Key Air 

LLC], for [Falcon 2000LX S/N 155 & N606TJ], we submit a petition for an exemption from a section 

of 14 CFR Part 135.156.

You will find in attachment to this letter the necessary information to support our petition.

Should you have any question, please do not hesitate to contact us at the following address:

[Gary Nylund]

[3 Juliano Dr Suite 201 Oxford, CT 06478]

[ 631-605-4243 or 203-264-0605]

mailto: 

[Gary Nylund

Key Air LLC

3 Juliano Dr Suite 201 Oxford CT 06478

]

 Petition For Exemption

In accordance with the requirements of 14 CFR §11.81(a)-(g), we provide the following detailed 

information in support of our petition:

14 CFR 11.81(a) - Contact information:

[Gary Nylund]

[3 Juliano Dr Suite 201 Oxford, CT 06478]

[ 631-605-4243 or 203-264-0605]

mailto: 

[Gary Nylund

Key Air LLC

3 Juliano Dr Suite 201 Oxford CT 06478

]

14 CFR 11.81(b) - Specific section from which relief is sought:

For [Falcon 2000LX S/N 155 & N606TJ], we request relief from the following portion of 14 CFR:

§135.156, Amdt 135-120, Flight data recorders: filtered data

(d) Compliance. Compliance is required as follows:

(4) After April 21, 2014, no aircraft flight data recording system may filter any 

parameter listed in paragraph (c) of this section that does not meet the requirements of 

Appendix D or F of this part, unless the certificate holder possesses test and analysis 

procedures and the test results that have been approved by the FAA. All records of tests, 

analysis and procedures used to comply with this section must be maintained as part of the 

correlation documentation required by § 135.152 (f)(1)(iii) or (f)(2)(iii) of this part as

applicable.

14 CFR 11.81(c) - Extent and reason for seeking relief:

For [Aircraft type & Registration], we are requesting an exemption from compliance with the above 

listed portions of the flight data recordersCompliance with the regulations requires retrofit with EASy 
14 CFR 11.81(c) - Extent and reason for seeking relief:

For [Falcon 2000LX S/N 155 & N606TJ], we are requesting an exemption from compliance with the 

above listed portion of the flight data recorders. Compliance with the regulations requires retrofit with 

EASy II upgraded avionics Load. Considering the large amount of Falcon aircraft being retrofitted with 

EASy II upgraded avionics, there is a significant waiting time before being accepted in a Service 

Center for retrofit. The amount of aircraft retrofitted monthly is limited worldwide, by the large amount 

of equipments to supply. Finally, this retrofit requires a significant downtime to adapt to scheduled 

maintenance checks in a way to maintain reasonable operational use of our aircraft. After review, we 

plan to retrofit our aircraft with EASY II upgraded avionics [2015]. 

14 CFR 11.81(d) - Public interest / benefit:

Being unable to operate [Falcon 2000LX S/N 155 & N606TJ] would have a significant economic 

burden on us. Denial of this petition would not be in the public's interest and would significantly reduce 

the operational capability of the affected aircraft, relegating these business aircraft to a state of reduced 

capability: indeed, Flight Data Recorder removal of data filtering is covered in EASy II global avionics 

upgrade offering others functionalities such ADS-B Out, FANS1A, ATNB1 or LPV. 

For the period in which the exemption would be in effect, there would not have any safety degradation. 

14 CFR 11.81(e) - Information supporting this petition:

This petition for exemption is related to the Flight Data recorder: data filtering to be removed, as 

mandated by 14 CFR §§135.156 Amendment 135-120. This exemption, if granted, would allow us to 

benefit from the commercial use of [Falcon2000LX S/N 155 & N606TJ] between April, 21, 2014 and 

[When Installed 2015].

If this petition is denied, then commercial flight operations of [Falcon 2000LX S/N 155 & N606TJ] 

will have to be interrupted until EASy II upgraded avionics retrofit is applied. 

Granting this exemption would not affect nor degrade the inherent safety of the airplane. This 

exemption deals only with the recording of pitch control surface position (parameter 15), lateral 

control surface position (parameter 16), yaw control surface position (parameter 17) and

cockpit flight control input forces (parameter 88); it therefore has no impact on operational safety.

14 CFR 11.81(f) - Federal Register summary:

Petitioner: [Key Air LLC]

Affected Regulations: 14 CFR §135.156(d)(4), Amdt 135-120.

Summary of Relief Sought: [Key Air LLC], seek exemption from section 14 CFR part 135.156 to 

allow [Falcon 2000LX S/N 155 & N606TJ] to operate with filtered data from April, 21, 2014 to 

[When Installed 2015].